In Belgium, audit season—often referred to as “busy season”—is a true test for finance departments. For many CFOs and chief accountants, the arrival of the statutory auditor is synonymous with stress, long evenings, and internal tension. Yet an audit should not be something you merely endure.
In a Belgian regulatory landscape shaped by the Code of Companies and Associations (CSA) and International Standards on Auditing (ISA), preparation is the only real performance lever. A well-prepared audit does more than certify financial statements: it strengthens credibility, reassures shareholders, and highlights the daily work of accounting teams.
This comprehensive guide provides a step-by-step methodology to turn a legal obligation into an exercise in financial and managerial control.
Understanding the Legal Framework and Stakes in Belgium
Before launching technical work, the entire accounting team must understand why the audit takes place and who the stakeholders are. Giving meaning is the first step toward engagement.
Who Is Subject to Audit in Belgium? (CSA Thresholds)
Since corporate law reform, the criteria triggering the appointment of a statutory auditor have evolved. For fiscal year 2025 (accounts for 2024), a company must appoint a statutory auditor if, for two consecutive years, it exceeds more than one of the following thresholds (Art. 1:24 CSA):
- Average workforce: 50 full-time equivalents
- Annual turnover (excl. VAT): EUR 9,000,000
- Total balance sheet: EUR 4,500,000
If the company belongs to a group required to prepare consolidated financial statements, the audit is often mandatory even if the Belgian entity itself is small.
Statutory Auditor vs Accountant
A frequent source of confusion, especially among junior staff:
- Accountant (ITAA certified): Helps prepare the accounts. Advisor to management.
- Statutory auditor (member of the IRE): Audits the accounts. Owes independence to shareholders and the public.
Preparing teams means clarifying this distinction: auditors do not post entries—they validate and challenge those already recorded.
The Objective: True and Fair View
The goal is not precision to the last cent. Audits operate on materiality thresholds. The objective is a true and fair view of the company’s financial position, in strict compliance with the PCMN (Belgian Minimum Chart of Accounts) and approved valuation rules.
Strategic Planning (D-120 to D-30)
A successful audit is decided well before year-end. Improvisation is the enemy of calm.
Interim Audit: The Key to Peace of Mind
Best practice is to schedule an interim audit in October or November (for a 31/12 closing).
Why it matters:
- Internal control testing: Purchasing, sales, payroll cycles are reviewed early.
- Complex topics validation: Acquisitions, ERP changes, leasing contracts—validate treatments before closing.
Hard Close: A Full Rehearsal
Perform an interim closing at 30 September or 31 October:
- Post depreciation
- Reconcile VAT
- Justify balance sheet accounts
What is validated at hard close won’t need to be reopened during final audit.
Shared Audit Calendar
Three months ahead, align internally and with auditors:
- Physical inventory date
- Final trial balance delivery
- Fieldwork weeks
- Adjustment deadline
- Board approval date
This calendar must be treated as non-negotiable.
The Core – Preparing the Audit File (Working Papers)
This is where the audit is won or lost. A clean, structured file reduces testing.
Cash & Banks (Class 5)
- Signed bank reconciliations
- Cash count reports
- Bank confirmations (balances + off-balance commitments)
Sales & Receivables (Classes 70 / 40)
- Cut-off testing (last invoices of N, first of N+1)
- Aged receivables with justification
- Accrued revenue documentation
Purchases & Payables (Classes 60–61 / 44)
- Accrued expenses comparison N vs N-1
- Review of debit supplier balances
Fixed Assets (Class 2)
- Asset movement table
- Impairment tests
- Supporting invoices above capitalization threshold
Inventory (Class 3)
- Written inventory procedures
- Consistent valuation method (FIFO, weighted average)
- Slow-moving stock write-downs
Payroll & Social Charges (Classes 62 / 45)
- Payroll reconciliation vs social secretariat
- Holiday pay provisions
- Benefits in kind (cars, phones, etc.)
Tax Cycle (Classes 67 / 45)
- Mandatory VAT turnover reconciliation
- Non-deductible expenses (DNA) detail
Internal Control – Your Shield
Strong internal controls reduce audit testing.
Segregation of Duties
If segregation is impossible, document compensating controls (e.g. CEO payment approval via Isabel).
Procedure Documentation
Provide updated process narratives:
- Supplier creation
- Expense approval
This builds immediate auditor trust.
IT General Controls (ITGC)
Prepare:
- User access lists
- Backup policies
- Change management procedures
The Human Factor
Audits are run by people, not spreadsheets.
Appoint an Audit Champion
Centralize auditor requests (PBC list) to protect junior staff and ensure consistency.
Logistics
- Dedicated audit room
- Read-only ERP access prepared in advance
Temporary Reinforcement
Use finance interim professionals to clean accruals and prepare files, avoiding burnout.
Behavioral Coaching
- Transparency
- Concise answers
- Professional courtesy
Digitalization and Data
Audits now analyze 100% of transactions.
Data Quality
- Clean descriptions
- Empty suspense accounts
Collaborative Platforms
Use SharePoint, Teams, or auditor portals with clear folder structures.
NBB XBRL Filing
Ensure software is aligned with latest NBB taxonomy.
Final Phase
Subsequent Events
Monitor events between closing and audit report signature.
Management Representation Letter
Review carefully—it carries legal responsibility.
Management Letter
Treat recommendations as a roadmap for improvement.
ESG & CSRD Impact
Even SMEs are increasingly affected.
Prepare teams for:
- Energy data
- Social indicators
Auditors will progressively certify sustainability data.
Conclusion
Preparing accounting teams for annual audits is a company-wide project. By structuring the process, anticipating issues, mastering PCMN specifics, and protecting people, audits become a validation—not a punishment.
A well-prepared team is a calm team. And a calm finance department is the foundation of a high-performing company.
🔗 Useful Resources
- Institute of Registered Auditors (IRE) – Audit standards and statutory auditors https://www.ibr-ire.be
- Belgian Accounting Standards Board (CNC) – Accounting opinions and PCMN guidance https://www.cnc-cbn.be
- National Bank of Belgium – Central Balance Sheet Office – Annual accounts filing (XBRL) https://www.nbb.be/en/central-balance-sheet-office
📚 Sources Used
- Belgian Code of Companies and Associations (CSA)
- PCMN – Belgian Minimum Chart of Accounts
- International Standards on Auditing (ISA)
- Fed Group – Finance recruitment & interim management expertise
Read Also
- A Step-by-Step Guide to Evaluating Finance and Accounting Job Offers in Belgium
- Mastering Job Interview Questions: A Strategic Guide for Financial Professionals
- How to Highlight Your Technical Skills in a Job Interview
- Why and How to Create a Perfect LinkedIn Profile in Belgium
- How to Follow Up with a Recruiter After a Job Interview
